I am resending this because I don't think this was posted the first time
I replied.
----- Forwarded by John Sparks/DC/USEPA/US on 01/11/02 07:34 AM -----
John Sparks
To: Listman <listman@wmrc.uiuc.edu>
01/10/02 08:44 cc:
AM Subject: Re: Are some regs driving
increased use of haz chemicals?(Document link:
John Sparks)
One focus of EPA's Design for the Environment Program( DfE) is to
provide companies industry-wide with a systematic tool that helps them
assess and implement cleaner technologies. This tool is the Cleaner
Technologies Substitutes Assessment or CTSA. The CTSA is a compilation
report of an assessment of promising substitutes for a specific
technology and compares cost, performance, environment impacts and
health and safety of available alternative technologies. A CTSA project
is a EPA-industry partnership that includes stakeholders from industry,
trade associations, academia, other governmental agencies and other
pertinent stakeholders groups. Working together, the partnership then
produces the CTSA report that provides the industry with information
that enables them to make an informed choice among possible substitutes.
Multiple examples of projects where this approach is used are on our web
site, www.epa.gov/dfe
Some lessons-learned: we have found that those who switch from a
regulated chemical to a non-regulated one do not necessarily make a
safer choice. There have been instances where a potential unregulated
substitute posed a greater relative risk that the one being replaced.
The CTSA approach helps an industry recognize this disparity.
An unofficial statistic: In DfE projects many of the chemicals included
as part of an assessment are not found on a regulated list or, otherwise
regulated. Of those not listed or regulated, our partnership have
found, that many pose significant moderate to high relative risk -- if
seen by the Agency as a "new" chemical, we would recommend further
regulatory action --- such as testing or, placement of controls, H&S
training, labeling, or a recommendation that alternative substances be
considered.
Listman
<listman@wmrc.uiuc To: p2tech@great-lakes.net
.edu> cc:
Sent by: Subject: Are some regs driving increased
owner-p2tech@great use of haz chemicals?
-lakes.net
01/07/02 03:24 PM
Please respond to
Listman
Forwarded on behalf of Burton Hamner--Please reply to the P2Tech
list or Mr. Hamner.
Thanks.
Any input to this project will be much appreciated!
Burton Hamner
www.cleanerproduction.com
Have environmental regulations, disclosure requirements, or product
bans =
caused companies to use more dangerous chemicals? Anecdotal
evidence, =
mostly from developing countries, indicates that some companies are
=
using petroleum or alcohol-based solvents in place of CFCs. This =
produces more hazardous waste, more VOC air pollution and increased
fire =
risk, despite reducing ozone depletion. There is also some
anecdotal =
evidence that TRI / Pollution Transfer &Release disclosure
requirements =
caused firms to substitute away from reportable chemicals to others
that =
might have more of an impact than the TRI chemical. We are
collecting =
any evidence of these changes in risks that might be available.
Our =
objective is to promote better understanding of comparative risk =
management in Cleaner Production and Pollution Prevention. A =
professional paper is being developed. If you have any examples
you can =
share with us we will be grateful and contact you for further
details. =
Please reply to=20
Mark Cohen, Professor, Vanderbilt University
Mark.Cohen@owen.vanderbilt.edu
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charset="iso-8859-1"
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Any input to this project will be much=20 appreciated!
Burton Hamner
www.cleanerproduction.com
Have=20 environmental = regulations, disclosure requirements, or=20
product bans caused companies to use more = dangerous=20 chemicals?
Anecdotal evidence, mostly from developing countries, =
indicates=20 that some companies are using petroleum or
alcohol-based solvents in = place of=20 CFCs. This produces more
hazardous waste, more VOC air = pollution and=20 increased fire
risk, despite reducing ozone depletion. There is also some
anecdotal evidence that TRI / Pollution Transfer=20 &Release
disclosure = requirements=20 caused firms to substitute away =
from=20 reportable chemicals to others = that might=20 have more of
an impact than = the TRI=20 chemical. We are collecting any
evidence of these changes in risks that might be = available.
Our=20 objective is to promote better understanding of comparative
risk = management in=20 Cleaner Production and Pollution
Prevention. A professional paper = is being=20 developed. If you
have any examples you can share with us we will = be=20 grateful
and contact you for further details. Please reply to=20
Mark Cohen, Professor, Vanderbilt=20 University
Mark.Cohen@owen.vanderbilt= .edu
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------------------------------
Jini Cook
List Manager
listman@wmrc.uiuc.edu
217.244-6553 jcook@wmrc.uiuc.edu